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SUPREME COURT HISTORY
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A mug shot of Ernesto Miranda.
A mug shot of Ernesto Miranda, whose wrongful conviction led to the landmark case Miranda v. Arizona, in which the Court held that detained criminal suspects must be informed of their rights prior to police questioning.

Reproduction courtesy of the Arizona Department of Corrections
Miranda v. Arizona (1966)

In Miranda v. Arizona (1966), the Supreme Court ruled that detained criminal suspects, prior to police questioning, must be informed of their constitutional right to an attorney and against self-incrimination. The case began with the 1963 arrest of Phoenix resident Ernesto Miranda, who was charged with rape, kidnapping, and robbery. Miranda was not informed of his rights prior to the police interrogation. During the two-hour interrogation, Miranda allegedly confessed to committing the crimes, which the police apparently recorded. Miranda, who had not finished ninth grade and had a history of mental instability, had no counsel present. At trial, the prosecution's case consisted solely of his confession. Miranda was convicted of both rape and kidnapping and sentenced to 20 to 30 years in prison. He appealed to the Arizona Supreme Court, claiming that the police had unconstitutionally obtained his confession. The court disagreed, however, and upheld the conviction. Miranda appealed to the U.S. Supreme Court, which reviewed the case in 1966.

The Supreme Court, in a 5-4 decision written by Chief Justice Earl Warren, ruled that the prosecution could not introduce Miranda's confession as evidence in a criminal trial because the police had failed to first inform Miranda of his right to an attorney and against self-incrimination. The police duty to give these warnings is compelled by the Constitution's Fifth Amendment, which gives a criminal suspect the right to refuse "to be a witness against himself," and Sixth Amendment, which guarantees criminal defendants the right to an attorney.

The Court maintained that the defendant's right against self-incrimination has long been part of Anglo-American law as a means to equalize the vulnerability inherent in being detained. Such a position, unchecked, can often lead to government abuse. For example, the Court cited the continued high incidence of police violence designed to compel confessions from a suspect. This and other forms of intimidation, maintained the Court, deprive criminal suspects of their basic liberties and can lead to false confessions. The defendant's right to an attorney is an equally fundamental right, because the presence of an attorney in interrogations, according to Chief Justice Warren, enables "the defendant under otherwise compelling circumstances to tell his story without fear, effectively, and in a way that eliminates the evils in the interrogations process."

Without these two fundamental rights, both of which, the Court ruled, "dispel the compulsion inherent in custodial surroundings," "no statement obtained from the defendant can truly be the product of his free choice."

Thus, to protect these rights in the face of widespread ignorance of the law, the Court devised statements that the police are required to tell a defendant who is being detained and interrogated. These mandatory "Miranda Rights" begin with "the right to remain silent," and continue with the statement that "anything said can and will be used against [the defendant] in a court of law." The police are further compelled to inform the suspect of his or her right to an attorney and allow for (or, if necessary, provide for) a defendant's attorney who can accompany him during interrogations. Because none of these rights was afforded to Ernesto Miranda and his "confession" was thus unconstitutionally admitted at trial, his conviction was reversed. Miranda was later retried and convicted without the admission of his confession.

Miranda v. Arizona, in creating the "Miranda Rights" we take for granted today, reconciled the increasing police powers of the state with the basic rights of individuals. Miranda remains good law today.

AUTHOR'S BIO
Alex McBride is a third year law student at Tulane Law School in New Orleans. He is articles editor on the TULANE LAW REVIEW and the 2005 recipient of the Ray Forrester Award in Constitutional Law. In 2007, Alex will be clerking with Judge Susan Braden on the United States Court of Federal Claims in Washington.

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